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Employee, Environment, Social and Governance report 2020 scottbader.com
1
SCOTTBADER.COM
SCOTT BADER
SUPPLIER
PARTNERSHIP
MANUAL
1 INTRODUCTION 3
2 SCOPE 6
3 PURPOSE 7
4 QUALITY 8
4.1 Quality management systems 8
4.2 Certificate of analysis 8
4.3 Non-conformance 8
4.4 Change management 8
4.5 Record keeping 8
5 ENVIRONMENT AND ENERGY 9
6 OCCUPATIONAL HEALTH AND
SAFETY MANAGEMENT 10
7 CHEMICAL CONTROL LEGISLATION 11
8 ETHICS 12
8.1 Child labour 12
8.2 Employment is freely chosen 12
8.3 Non-discrimination 12
8.4 Hours of work 12
8.5 Wages and benefits 13
8.6 Employee treatment 13
8.7 Agency labour 13
8.8 Anti-bribery and corruption 13
8.9 Conflict minerals 13
8.10 Lead free 13
8.11 Sub-contractors 13
8.12 Reporting Misconduct 14
8.13 Sanctioned Parties 14
9 SUPPLIER APPROVAL AND MONITORING 15
9.1 Approvals 15
9.2 Ecovadis 15
9.3 Monitoring 15
10 REVISIONS 16
10.1 Revision table 16
CONTENTS
Scott Bader Supplier Partnership Manual
2
Scott Bader Supplier Partnership Manual
3
Until 2020
Scott Bader Supplier Partnership Manual
3
1. INTRODUCTION
Scott Bader Company Limited (SBCL ā€“ ā€˜the Companyā€™) is a
multinational speciality chemical company with a turnover
around Ā£200m, employing c.a. 700 people worldwide and
is a recognised leader in the manufacture of adhesives,
gelcoats, resins and functional polymers.
The Company was formed as a chemicals merchant in 1921
by Ernest Bader. Scott Bader moved to Northamptonshire
in 1940 where its headquarters remain today.
In 1951, the Bader family gifted the Company shares to
The Scott Bader Commonwealth Limited, an independent
company with no external shareholders and a distinct self-
governing structure ā€˜owned in commonā€™ by all who work in it.
Scott Bader has expanded to be a global company with 7
Manufacturing sites and 9 Sales offices around the world.
The founder Ernest Bader wanted to create an environment
where profits would be shared amongst the workers, and
believed that a business should be:
ā€¢ Founded on ethical principles
ā€¢ Organised democratically
ā€¢ Contribute to the good of society
This vision is highly consistent with the current expectations
underpinning the movement on ESG reporting.
Today Scott Bader features in the Employee Ownership
Associationā€™s (EOA) 2020 Top 50 Report as one of the fifty
largest employee-owned companies in the UK. It is a prime
example of how a business can be run differently, whilst also
being successful. As it cannot be taken over, the Company is
able to think and act long term as a business, with colleagues
fully involved in both the business strategy and operations.
We continue to maintain the balance between our social
purpose and our business needs as we pursue our ambitious
2036 Vision, in a way that lives up to our founder Ernest
Baderā€™s vision.
Scott Bader Supplier Partnership Manual
4
1 STRIVING FOR
EXCELLENCE
We are purpose-driven, fully meeting the
expectations of our customers by continuously
improving all our processes and products to
deliver world-class business performance.
OUR 7 STRATEGIC GOALS
3 ACTING BEYOND
COMPLIANCE
We are a trusted leader, proactively driving a
safe, transparent and ethical chemical industry,
promoting exemplary conduct to deliver products
and processes that safeguard people and planet.
2 PIONEERING THE
CIRCULAR ECONOMY
We are a recognised circular economy
practitioner, collaborating with our partners
to optimise our combined resources for a waste
and harm-free, closed-loop value chain.
4 DELIVERING VALUE TO SOCIETY
We are advocating sustainability, sharing our
know-how, profit and Commonwealth vision,
and supplying products and services that provide
real value to society.
5 UNLEASHING
COLLEAGUESā€™ POTENTIAL
We are driven by the diversity and creativity of
our people who are empowered and motivated
to make a difference through initiative and
innovation at every level of the organisation.
7 PROTECTING OUR
ENVIRONMENT
We are a strong ambassador for the transition
to a sustainable planet through our responsible
use of our natural resources, our stewardship
of clean energy and fresh water, and our
commitment to zero emissions.
6 PARTNERING FOR SUCCESS
We are at the heart of a global network
of mutually-beneficial partnerships with
suppliers, customers and world-leading
allies who are engaged with our mission
and share our vision.
We envision a world where humanity
thrives, without compromising the natural
systems it depends on. Scott Bader provides
essential technologies that address the
challenges of our changing society and in
doing so is a renowned, trustworthy partner
that is globally admired for harnessing the
power of chemistry as a force for good.
Scott Bader Supplier Partnership Manual
5
The purpose of Scott Bader has been restated
recognising that our ability to deliver for
our customers depends on empowering our
people. To this end the strategy and the steps
required to implement the strategy have been
summarised, with clear targets for 2025 within
each of the three pillars of Humanity, Business,
and Ecology as milestones on our journey
towards the 2036 Vision.
PEOPLE AND VALUES
ā€¢ Integrity and honesty
ā€¢ Commit and deliver
ā€¢ Teamwork
ā€¢ Diversity and Inclusion
ā€¢ Fairness and equality
ā€¢ Innovation and empowerment
ā€¢ Compassion and care
"Be the best we can be"
APPROACH AND PRINCIPLES
ā€¢ Safety and wellbeing
ā€¢ Ethical business
ā€¢ Sustainability
ā€¢ Responsible stewardship
ā€¢ Beyond compliance
ā€¢ Promote Scott Bader values
"To solve customer problems"
IMPACT ON SOCIETY
ā€¢ Reduced emissions
ā€¢ Reduced waste
ā€¢ Sustainable products
ā€¢ Supplying sustainable industries
ā€¢ Development of colleagues
ā€¢ Charity and volunteering
ā€¢ Investment in local communities
"...and make a positive
difference globally..."
OUR 2036 VISION WAS DEVELOPED WITH REFERENCE TO
THE UNITED NATIONS SUSTAINABLE DEVELOPMENT GOALS
Scott Bader Supplier Partnership Manual
6
2. SCOPE
This manual describes Scott Baderā€™s Quality and CSR requirements for
suppliers and contractors, who provide raw materials, tolled products,
additional processing, services and on-site contracting activities.
This manual specifies the Quality and CSR requirements for Scott Bader Suppliers and
does not supersede specifications or contractual agreements, which shall be reviewed
and agreed, in addition to these requirements.
Suppliers are required to cascade these requirements or equivalent to their own
suppliers throughout the supply chain.
Scott Bader may have additional specific requirements beyond the requirements of this
manual, these will be issued by the Local Purchasing or QA teams. This may encompass
Logistical requirements including booking in and site rules, additional regulatory
paperwork and other legal requirements of the site you are supplying.
If in doubt, please contact your Local Scott Bader Purchasing or QA contact.
Scott Bader reserves the right to monitor suppliers, and where applicable, external
manufacturer compliance, in line with this Partnership Manual. Suppliers and/
or external manufacturers that are not in compliance with this Partnership Manual
are expected to implement corrective action and any future partnerships are at the
discretion of Scott Bader.
This manual specifies the
Quality and CSR requirements
for Scott Bader Suppliers.
CSR
Scott Bader Supplier Partnership Manual
7
We seek to develop long-term
partnerships with our suppliers
that are mutually beneficial.
3. PURPOSE
These requirements in this manual are designed to support
Scott Baderā€™s 2036 Vision, in particular, Acting beyond
compliance and Partnering for Success.
The purpose of this manual is to inform Scott Baderā€™s Suppliers of our core
expectations regarding their Quality, Safety and Environmental Management,
Ethics and Corporate Social Responsibilities. After reviewing this manual, a supplier
should have a clear understanding of what is expected of them to ensure that
all Scott Baderā€™s requirements and expectations are being met.
We seek to develop long-term partnerships with our suppliers that are mutually
beneficial. We work closely with suppliers, that reflect the values of Scott Bader,
who develop greener solutions, promote sustainability at every opportunity and who
share our commitment to achieve increasing levels of customer satisfaction, quality,
safety, sustainability and ethics through continuous improvement and monitoring.
We will conduct our business with the highest level of integrity. We will be honest
and responsible in dealing with suppliers and contractors.
Scott Bader expects our suppliers to deliver quality product on time with no defects
at a cost that enables both of us to be competitive and viable. We expect our suppliers
to be proactive and to alert us of any potential problems, changes in process or
products and situations that may arise causing risk to our joint ability to meet our
Quality, Regulatory and Ethical contractual obligations to our customers.
We expect quality and timely
delivery at a cost that is mutually
competitive and viable.
scottbader.com 8
4. QUALITY
4.1 QUALITY MANAGEMENT SYSTEMS
Scott Bader expects all our key suppliers to be certified to, as a minimum,
ISO 9001:2015 or actively working towards gaining certification, unless prior
approval is obtained by Scott Bader
The supplier shall maintain suitable procedures and work instructions and ensure
that all persons including delivery drivers relating to the supplied products or services
supplied are suitably trained and competent.
Product must be delivered with appropriate paperwork, in the agreed packaging of
good condition to allow for suitable storage and lot/batch numbers must be clearly
visible and legible on each individual package.
4.2 CERTIFICATE OF ANALYSIS
Where applicable all products must be delivered with a certificate of analysis,
clearly detailing the test results of the delivered product, the batch/lot number
and the manufacturing or expiry date of the delivered product in accordance with,
where applicable, the agreed Scott Bader Purchasing Specification.
Full traceability must be maintained by the supplier, with the delivered product being
traceable back to base materials and equipment used to produce the product.
4.3 NON-CONFORMANCE
In the event that a supplierā€™s product or service does not conform to the agreed
specifications then Scott Bader will issue a Non-Conformance/Supplier Complaint.
Once issued the supplier will acknowledge the complaint and commence investigation
to the root cause with the expectation (unless agreed otherwise in writing) to fully
investigate, complete and close out the Non-Conformance/Complaint including all
corrective actions and preventative actions to ensure the issue does not re-occur.
4.4 CHANGE MANAGEMENT
The supplier must inform Scott Bader of any changes to the product formulation,
processing equipment (that is not like for like), manufacturing location, specification
or packaging.
In the case of a non ā€œforce majeureā€ change then notice of the change must be given at
least 3 months before the change is implemented and must allow for continued supply
of existing material for 6 months from notification. The supplier must have a change
management process in place and this must be clearly communicated to Scott Bader.
4.5 RECORD KEEPING
The supplier shall implement a suitable document control and record keeping process
to ensure that records are available for, as a minimum, 36 months beyond the shelf life
of the materials supplied to enable full traceability of the supplied product.
Scott Bader expects all our key
suppliers to be certified to,
as a minimum, ISO 9001:2015
Scott Bader Supplier Partnership Manual
9
5.0 ENVIRONMENT
AND ENERGY
Scott Bader expects all our suppliers to implement an Environmental
and Energy Management System and certification to ISO14001:2015 and
ISO 50001:2018 is preferred which will lower the risk rating of the supplier.
Suppliers shall obtain, keep current, and comply with all required local
Environmental permits.
We aim to work and build partnerships with suppliers who actively seek to secure
raw materials using non-crude oil or ā€˜Green/Bioā€™ feed materials and environmentally
friendly processes, where possible.
All suppliers should have an active waste reduction plan in place including for internal
activities and for products and packaging supplied to Scott Bader.
Suppliers should have a plan to monitor and actively reduce their Energy usage and
GHG emissions in order to limit the impact on the environment.
Supplierā€™s facilities shall be suitably controlled as to minimise emissions to air,
land or water, this includes odour and noise disruptions in the local area.
External manufacturers will comply with all applicable transportation laws. External
manufacturers will have systems in place to ensure safe and secure transportation of
materials, and such systems should be considered when: selecting logistics service
providers (including warehouses and terminals), inspecting and labelling of transport
containers, loading and unloading of transport containers, securing and sealing of
transport containers and responding to emergencies.
All suppliers should have
an active waste reduction
plan for internal activities,
products and packaging.
scottbader.com 10
6. OCCUPATIONAL
HEALTH AND SAFETY
MANAGEMENT
Suppliers shall have sound H&S
practices to prevent workplace
accidents and injuries.
Scott Bader expects all our suppliers to implement a Health & Safety
Management System, including accident and near miss reporting.
Certification to ISO 45001:2018 is preferred which will lower the risk
rating of the supplier.
Suppliers shall obtain, keep current, and comply with all required local health and safety
permits and relevant regulations.
Suppliers shall provide a safe and healthy environment to prevent workplace accidents
and injuries and integrate sound health and safety management practices into their
business. Workers shall have the right to refuse unsafe work and to report unhealthy
working conditions.
Suppliers shall identify, evaluate, and manage occupational health and safety hazards
through a prioritised process of hazard elimination, substitution, engineering controls,
administrative controls, and/or personal protective equipment.
Occupational exposure to potential safety hazards and emergency situations shall be
controlled through proper design, risk assessment, engineering controls, safe work
procedures, emergency plans and response procedures, and mandatory trainings.
Facilities and onsite accommodation for employees must safeguard individualsā€™ dignity,
hygiene and safety. Their conditions must comply with national laws and relevant
health and safety standards.
Scott Bader Supplier Partnership Manual
11
7. CHEMICAL CONTROL
LEGISLATION
Scott Bader is a primarily a formulator of chemical mixtures and manufacturer
of polymers that may be sold globally. We have obligations to communicate
hazard and safe use information to our customers and to inform our suppliers
of any additional suspected hazards or new uses of their products that are
not covered by existing chemical safety assessments. Therefore, Scott Bader
seeks to work closely with suppliers in ensuring both parties are able to
comply with chemical control legislation around the world.
Suppliers shall cooperate with Scott Bader in maintaining compliance of their products
in the UK and of any Scott Bader products (mixtures or polymers) made using their
supplied materials in any relevant market Scott Bader supplies. Communication on
chemical inventory status of their materials globally is required and the supplier shall
clarify the status of their Registrations (e.g., EU, UK, Turkey REACH), notifications
(e.g. TSCA, DSL, AICIS, Japan ISHL/CSCL) as well as any industry declarable
substances lists (e.g. GADSL).
It is accepted that not all materials may be able to comply with all regions and the
supplier shall clearly communicate their status in each jurisdiction and/or market
(including food contact, personal care, automotive etc). The supplier shall work with
Scott Bader to clarify, establish or maintain compliance as required and agreed with
Scott Bader.
Suppliers shall inform Scott Bader prior to sale if their product contains any controlled
or restricted substances (REACH restrictions, RoHS, TSCA Section 6 rulings or Section
5 SNURS etc) that could reasonably be foreseen to affect the use of the substance by
Scott Bader in their manufacturing site or in product mixtures sold in or outside of the
UK (for example those subject to REACH Restrictions, Authorisation list substances,
Candidate List substances, Prior Informed Consent, TSCA Section 12(b), Rotterdam
convention, Stockholm Convention, Chemical Weapons Conventions, dual-use
regulations etc.).
All products supplied must comply GHS classification and labelling regulations (GB CLP)
including provision of extended Safety Data Sheets (eSDS). Changes to product labels
or SDS must be communicated to Scott Bader Regulatory Affairs as soon as practicable
or within three months of the change occurring. This is to meet our legal obligations
in other countries in a timely fashion and ensure we can communicate to our
downstream users.
The supplier should also communicate any expected changes in their products
regulatory status or hazard classification as soon as possible to enable the supplier
and Scott Bader to make any adjustments to processes, packaging or any downstream
communication needs.
All products supplied must comply
with GHS classification and
labelling regulations (GB CLP).
GHS
scottbader.com 12
8. ETHICS
8.1 NO CHILD LABOUR
Child labour is not tolerated in any form. Suppliers shall not directly or indirectly
employ children below the minimum age of 15, unless exceptions under ILO Minimum
Age Convention No. 138 Article 6-7 apply.
Suppliers should have a child labour policy and a plan for remediation if applicable.
If a child is found working at a site associated with a Supplier, all remedial actions
taken must be in the best interest of the child. It is of the highest importance to always
protect children from being forced into harmful work.
Employees younger than 18 years of age are acceptable, providing that they do not
perform work that might jeopardise their health or safety, consistent with ILO
Minimum Age Convention No. 138. Suppliers shall not require juvenile workers to
work overtime or perform night-time work.
8.2 EMPLOYMENT IS FREELY CHOSEN
There shall be no forced, bonded or involuntary prison labour or any form of human
slavery, servitude or human trafficking.
ā€˜Human traffickingā€™ means the recruitment, transportation, transfer, harbouring or
receipt of persons, by means of the threat or use of force or other forms of coercion,
of abduction, of fraud, of deception, of the abuse of power or of a position of
vulnerability or of the giving or receiving of payments or benefits to achieve
the consent of a person having control over another person, for the purpose of
exploitation.
Scott Bader strictly prohibits any exploitative labour practices or any associated
criminal conduct within its supply chain.
Workers shall not be required to lodge ā€œdepositsā€ or their passports / identity papers
with their employer and are free to leave their employer after reasonable notice. Where
applicable, suppliers must abide by the Modern Slavery Act 2015, or the local equivalent in
their country, and be able to demonstrate compliance throughout their entire supply chain.
8.3 NON-DISCRIMINATION
Suppliers shall not negatively discriminate based on race, colour, age, gender, sexual
orientation, gender identity and expression, ethnicity or national origin, disability,
pregnancy, religion, political affiliation, union membership, protected genetic
information or marital status in hiring and employment practices unless such
distinction is required by national law, such as BBBEE in South Africa.
8.4 HOURS OF WORK
Employees should not be required to work more than the maximum regular and
overtime hours allowed by the law of the country of operation. No more than 48 hours
per week are worked on a regular basis and no more than 12 hours per week overtime
on a regular basis.
Overtime must be voluntary and not used to replace regular contracted hours.
Workers must be compensated at a premium rate according to national law.
Holidays should be granted in accordance with local laws and employees shall be given,
except in extraordinary business circumstances, at least one day off per week.
Child labour is not
tolerated in any
form, either directly
or indirectly.
We strictly prohibit exploitative
labour or criminal conduct within
our supply chain.
Scott Bader Supplier Partnership Manual
13
8.5 WAGES AND BENEFITS
Wages and benefits paid for the standard working week must meet, as a minimum,
national legal standards.
All workers shall be provided with written and understandable information about their
employment conditions in respect to wages before they enter employment and about
the particulars of their wages for the pay period concerned each time that they are paid
including any deductions at a rate that is fair and reasonable by local standards and
must be lawful and not discriminatory. Ensuring that the deductions from wages as a
disciplinary measure shall not be permitted without the expressed permission of the
worker concerned. All disciplinary measures should be recorded.
8.6 EMPLOYEE TREATMENT
Every employee shall be treated with respect and dignity. Workers shall not be subject
to any discrimination either directly or indirectly based on their gender, race, religion
disability or any other protected characteristic or any form of physical, sexual or mental
harassment or verbal abuse
8.7 AGENCY LABOUR
If workers are sourced from a third party, suppliers must ensure that the third party
is reputable and (if required) properly licensed.
Suppliers must take reasonable steps to ensure that all workers supplied have the right
to work in the country of operation and are engaged on terms that comply at least the
minimum legal requirements in that country.
8.8 ANTI-BRIBERY AND CORRUPTION
Scott Bader does not tolerate any form of bribery and corruption.
We recognise that market practice varies across the territories in which Scott Bader
does business and therefore, what is normal and accepted in one place may not
be accepted in another. However, we are fully committed to complying with our
obligations under all applicable legislation, including the UKā€™s Bribery Act 2010 and
ensuring that no bribes or corrupt payments are made, offered, sought or obtained by
anyone acting on behalf of Scott Bader, anywhere in the world and expects its supply
partners to adhere to the same standards.
8.9 CONFLICT MINERALS
Suppliers must ensure that products and goods supplied to Scott Bader do not contain
metals or materials that are derived from minerals originating from conflict regions.
Conflict minerals are tantalum, tin, tungsten and gold, also known as 3TG, and their
derivatives that directly or indirectly finance or benefit armed groups.
8.10 LEAD FREE
Scott Bader works to a ā€œlead freeā€ policy across the group to ensure the health of all our
colleagues, while processing and working with raw materials. All suppliers must ensure
that all products supplied to Scott Bader UK are free from lead.
8.11 SUB-CONTRACTORS
Suppliers and contractors for Scott Bader must ensure any sub-contractors are aware
of and comply with the requirements of this Supplier Partnership Manual.
8. ETHICS
Every employee shall be treated
with respect and dignity.
Scott Bader does not tolerate any
form of bribery and corruption.
Scott Bader Supplier Partnership Manual
14
8.12 REPORTING MISCONDUCT
An external manufacturer who believes that a Scott Bader employee or anyone
acting on behalf of Scott Bader has engaged in illegal or otherwise improper conduct
with respect to their business with the supplier should report the matter, in the first
instance, to Scott Bader for resolution. Reports may be made through the Scott Bader
Whistleblowing Hotline that is operated by an external service provider, Safecall, who
can be reached at http:/
/www/safelink.co.uk/report. Any such report of potential
misconduct shall not adversely affect the parties relationship.
8.13 SANCTIONED PARTIES
Any supplier and/or shipper shall not use an external manufacturer for services or
equipment which: (a) is located in any country subject to United Nations, United States
or European Union sanctions (or acting on behalf of persons or entities located in such
countries); or (b) appears on lists of restricted or prohibited persons maintained by the
United Nations, United States or the European Union or the country of manufacture,
origin, destination of the cargo. Where applicable, a shipper shall screen all vessels,
containers and other equipment and their owners to ensure compliance with this
requirement.
8. ETHICS
scottbader.com 15
9. SUPPLIER APPROVAL
AND MONITORING
Scott Bader is committed to
working with suppliers whose
values are aligned to ours.
9.1 APPROVALS
Scott Bader applies a risk-based process to supplier approval, based on several different
criteria including Business Impact to Scott Bader, ISO approvals, single sourcing and
CSR activities including Ecovadis score.
All suppliers will be required to complete a Supplier approval questionnaire and agree
to the requirements of this Manual prior to approval.
Once the questionnaire has been reviewed a risk score will be allocated and approval
can take place. Based on the risk score this approval may involve a full supplier audit,
either on site or desk based.
Suppliers must agree to allow a Scott Bader representative on site to carry out a full
system/process audit if required.
9.2 ECOVADIS
Scott Bader is committed to working with suppliers whose values are aligned to ours.
Scott Bader has signed up to EcoVadis, a world leading provider of business supplier
sustainability ratings and improvement tools for global supply chains. We will leverage
this platform to reduce risk, encourage innovation and deliver on our commitment to
put sustainability and ethics at the core of what we do. EcoVadis support Scott Baderā€™s
mission to measure, monitor and improve supplier performance across key sustainability
criteria and identify high-performing partners willing to collaborate with us.
It is recommended that all suppliers to Scott Bader are registered on Ecovadis and that
their scorecard is shared with us. Completion of this will reduce the risk score of the
supplier approval.
Scorecards will be reviewed; minimum category scores may be set and continual
improvement of the Ecovadis score may be required to maintain approval as a supplier.
9.3 MONITORING
Key Suppliers will be monitored based OTIF and Quality performance, including
complaints and supplier responsiveness.
Suppliers monitored will be listed in the following categories
ā€¢ Good
ā€¢ Satisfactory
ā€¢ Needs Improvement
For Suppliers identified in the ā€œNeeds Improvementā€ category Scott Bader may
request an improvement plan and / or surveillance audit and failure to improve their
performance may result in approval being revoked.
Suppliers will also be monitored against the CSR requirements of this manual and any
breaches which do not fit in with the ethics and values of Scott Bader may also result in
approval being revoked.
All suppliers complete
a questionnaire and agree
to the requirements of this
manual prior to approval.
Scott Bader Supplier Partnership Manual
16
10. REVISIONS
Any updates to the Supplier Partnership Manual will be posted
on the Scott Bader website.
Suppliers shall regularly check the current version they have on hand
with the latest version.
All changes to this manual shall be identified on the revision table below.
Scott Bader welcomes any feedback about corrections and suggestions for
improvement including suggestions for adding additional information.
REV DATE UPDATES APPROVED BY
0.1 20/11/2021 Final group draft D.Black
0.2
Addition of misconduct
and sanctions clauses in
section 8
D.Black
10.1 REVISION TABLE
scott
bade
r.com
12
8.0 ETHICS
8.1
CHI
LD
LAB
OUR
Chil
d labo
ur is not
tole
rate
d in any
form
. Sup
plie
rs shal
l not
dire
ctly
or indi
rect
ly
emp
loy
chil
dren
belo
w the
min
imu
m age
of 15,
unle
ss exce
ptio
ns und
er ILO
Min
imu
m
Age
Con
ven
tion
No.
138
Arti
cle
6-7
app
ly.
Sup
plie
rs sho
uld
hav
e a chil
d labo
ur poli
cy and
a plan
for
rem
edia
tion
if app
licab
le.
If a chil
d is foun
d wor
king
at a site
asso
ciat
ed with
a Sup
plie
r, all rem
edia
l acti
ons
take
n
mus
t be in the
best
inte
rest
of the
chil
d. It is of the
high
est
imp
orta
nce
to alwa
ys prot
ect
chil
dren
from
bein
g forc
ed into
harm
ful wor
k.
Emp
loye
es you
nge
r than
18
year
s of age
are
acce
ptab
le, prov
idin
g that
they
do not
perf
orm
wor
k that
mig
ht jeop
ardi
se thei
r hea
lth
or safe
ty, con
siste
nt with
ILO
Min
imu
m Age
Con
ven
tion
No.
138
. Sup
plie
rs shal
l not
requ
ire
juve
nile
wor
kers
to
wor
k ove
rtim
e or perf
orm
nigh
t-tim
e wor
k.
8.2
EMP
LOY
MEN
T IS FRE
ELY
CHO
SEN
The
re shal
l be no forc
ed,
bon
ded
or invo
lunt
ary
pris
on labo
ur or any
form
of hum
an
slav
ery,
serv
itud
e or hum
an traf
fick
ing.
ā€˜Hum
an traf
fick
ingā€™
mea
ns the
recr
uitm
ent,
tran
spo
rtat
ion,
tran
sfer
, harb
ouri
ng or
rece
ipt
of pers
ons
, by mea
ns of the
thre
at or use
of forc
e or othe
r form
s of coe
rcio
n,
of abd
ucti
on,
of frau
d, of dec
epti
on,
of the
abu
se of pow
er or of a pos
ition
of
vuln
erab
ility
or of the
givi
ng or rece
ivin
g of pay
men
ts or ben
efits
to achi
eve
the
con
sent
of a pers
on hav
ing
con
trol
ove
r ano
ther
pers
on,
for
the
purp
ose
of exp
loita
tion
.
Sco
tt Bad
er stric
tly proh
ibits
any
exp
loita
tive
labo
ur prac
tice
s or any
asso
ciat
ed
crim
inal
con
duc
t with
in its sup
ply
chai
n.
Wor
kers
shal
lnot
berequ
ired
tolodg
eā€œdep
osit
sā€orthei
rpass
port
s/iden
tity
pap
ers
with
thei
remp
loye
rand
are
free
toleav
ethei
remp
loye
rafte
rreas
ona
ble
noti
ce.Wh
ere
app
licab
le,supp
liers
mus
tabid
ebythe
Mod
ern
Slav
ery
Act
201
5,orthe
loca
lequ
ivale
ntin
thei
rcoun
try,
and
beable
todem
onst
rate
com
plian
cethro
ugh
out
thei
renti
resupp
lychai
n.
8.3
NO
N-D
ISCR
IMI
NAT
ION
Sup
plie
rs shal
l not
neg
ativ
ely
disc
rimi
nate
base
d on race
, colo
ur, age
, gen
der,
sexu
al
orie
ntat
ion,
gen
der
iden
tity
and
exp
ress
ion,
ethn
icity
or nati
ona
l orig
in, disa
bilit
y,
preg
nan
cy, relig
ion,
poli
tica
l affil
iatio
n, unio
n mem
bers
hip,
prot
ecte
d gen
etic
info
rma
tion
or mar
ital
stat
us in hirin
g and
emp
loym
ent
prac
tice
s unle
ss such
dist
inct
ion
is requ
ired
by nati
ona
l law,
such
as BBB
EE
in Sou
th Afri
ca.
8.4
HO
URS
OF
WO
RK
Emp
loye
es sho
uld
not
be requ
ired
to wor
k mor
e than
the
max
imu
m regu
lar
and
ove
rtim
e hou
rs allo
wed
by the
law
of the
cou
ntry
of ope
ratio
n. No
mor
e than
48
hou
rs
per
wee
k are
wor
ked
on a regu
lar
basi
s and
no mor
e than
12
hou
rs per
wee
k ove
rtim
e
on a regu
lar
basi
s.
Ove
rtim
e mus
t be volu
ntar
y and
not
used
to repl
ace
regu
lar
con
trac
ted
hou
rs.
Wo
rker
s mus
t be com
pen
sate
d at a prem
ium
rate
acco
rdin
g to nati
ona
l law.
Hol
iday
s sho
uld
be gran
ted
in acco
rdan
ce with
loca
l laws
and
emp
loye
es shal
l be give
n,
exce
pt in extr
aord
inar
y bus
ines
s circ
ums
tanc
es,
at leas
t one
day
off
per
wee
k.
Child lab
our
is not
tolera
ted
in any
form, eith
er dire
ctly
or ind
irec
tly.
We
strictl
y pro
hib
it exp
loit
ativ
e
lab
our
or crim
ina
l con
duc
t
wit
hin
our
sup
ply
cha
in.
Employee, Environment, Social and Governance report 2020 scottbader.com
1
SCOTTBADER.COM
SCOTT BADER
SUPPLIER
PARTNERSHIP
MANUAL
Scott Bader Supplier Partnership Manual
6
2.0 SCOPE
This manual describes Scott Bader Co Ltd.ā€™s Quality and CSR requirements
for suppliers and contractors, who provide raw materials, tolled products,
additional processing, services and on-site contracting activities.
This manual specifies the Quality and CSR requirements for Scott Bader Suppliers and
does not supersede specifications or contractual agreements, which shall be reviewed
and agreed, in addition to these requirements.
Suppliers are required to cascade these requirements or equivalent to their own
suppliers throughout the supply chain.
Scott Bader may have additional specific requirements beyond the requirements of this
manual, these will be issued by the Local Purchasing or QA teams. This may encompass
Logistical requirements including booking in and site rules, additional regulatory
paperwork and other legal requirements of the site you are supplying.
If in doubt, please contact your Local Scott Bader Purchasing or QA contact.
This manual specifies the
Quality and CSR requirements
for Scott Bader Suppliers.
CSR
scottbader.com 17
SCOTT BADER GROUP COMPANIES
Registered office address: Scott Bader Company Limited, Wollaston Hall, Wollaston, Wellingborough, Northamptonshire, NN29 7RL. Registered in England No. 00189141.
SCOTTBADER.COM
Head Office
Scott Bader Company Limited
Wollaston, England
Tel: +44 (0) 1933 663100
Email: enquiries@scottbader.com
Scott Bader France
Amiens, France
Tel: +33 3 22 66 27 66
Email: info@scottbader.fr
Scott Bader Spain
Barcelona, Spain
Tel: +34 93 553 1162
Email: diazs@scottbader.es
Scott Bader Germany
Weiden, Germany
Tel: +49 961 401 84474
Email: composites@scottbader.de
Scott Bader Ireland
Dublin, Ireland
Tel: +353 1801 5656
Email: composites@scottbader.ie
Scott Bader Scandinavia
Falkenberg, Sweden
Tel: +46 346 10100
Email: composites@scottbader.se
Scott Bader Eastern Europe s.r.o.
Praha 6, Czech Republic
Tel: +420 (0) 485 111 253
Email: composites@scottbader.cz
Scott Bader Croatia
Zagreb, Croatia
Tel: +385 1 240 6440
Email: info@scottbader.hr
Scott Bader North America
Stow, OH, USA
Tel: +1 330 920 4410
Email: info@scottbader-na.com
Scott Bader North America
Mocksville, NC, USA
Email: info@scottbader-na.com
Scott Bader ATC
Drummondville, Canada
Tel: +1 (819) 477 1752
Email: enquiries@scottbader.com
Scott Bader South Africa
Hammarsdale, South Africa
Tel: +27 31 736 8500
Email: composites@scottbader.co.za
Scott Bader Middle East
Dubai, United Arab Emirates
Tel: +971 481 50 222
Email: info@scottbader.ae
Scott Bader Asia Pacific
Shanghai, China
Tel: +86 (21) 5298 7778
Email: info@scottbader.cn
Scott Bader Japan KK
Yokohama, Japan
Tel: +81 (0) 45 620 3745
Email: enquiries@scottbader.com
Scott Bader Australia
Perth, Australia
Tel: +61 (08) 9418 4555
Email: info@scottbader.com.au
Saryen Scott Bader Pvt. Ltd
Mumbai, India
Tel: +91 22 4220 1555
Email: info@satyenpolymers.com
NovaScott Especialidades QuĆ­micas Ltda
Civit II, Serra, ES 29165-973, Brazil
Tel: +55 27 3298 1100
Email: info@novascott.com.br
Scott Bader Italy
Emilia Romagna, Italy
Tel: +39 3454534391
Email: enquiries@scottbader.com

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Scott-Bader-Supplier-Partnership-Manual.pdf

  • 1. Employee, Environment, Social and Governance report 2020 scottbader.com 1 SCOTTBADER.COM SCOTT BADER SUPPLIER PARTNERSHIP MANUAL
  • 2. 1 INTRODUCTION 3 2 SCOPE 6 3 PURPOSE 7 4 QUALITY 8 4.1 Quality management systems 8 4.2 Certificate of analysis 8 4.3 Non-conformance 8 4.4 Change management 8 4.5 Record keeping 8 5 ENVIRONMENT AND ENERGY 9 6 OCCUPATIONAL HEALTH AND SAFETY MANAGEMENT 10 7 CHEMICAL CONTROL LEGISLATION 11 8 ETHICS 12 8.1 Child labour 12 8.2 Employment is freely chosen 12 8.3 Non-discrimination 12 8.4 Hours of work 12 8.5 Wages and benefits 13 8.6 Employee treatment 13 8.7 Agency labour 13 8.8 Anti-bribery and corruption 13 8.9 Conflict minerals 13 8.10 Lead free 13 8.11 Sub-contractors 13 8.12 Reporting Misconduct 14 8.13 Sanctioned Parties 14 9 SUPPLIER APPROVAL AND MONITORING 15 9.1 Approvals 15 9.2 Ecovadis 15 9.3 Monitoring 15 10 REVISIONS 16 10.1 Revision table 16 CONTENTS Scott Bader Supplier Partnership Manual 2
  • 3. Scott Bader Supplier Partnership Manual 3 Until 2020 Scott Bader Supplier Partnership Manual 3 1. INTRODUCTION Scott Bader Company Limited (SBCL ā€“ ā€˜the Companyā€™) is a multinational speciality chemical company with a turnover around Ā£200m, employing c.a. 700 people worldwide and is a recognised leader in the manufacture of adhesives, gelcoats, resins and functional polymers. The Company was formed as a chemicals merchant in 1921 by Ernest Bader. Scott Bader moved to Northamptonshire in 1940 where its headquarters remain today. In 1951, the Bader family gifted the Company shares to The Scott Bader Commonwealth Limited, an independent company with no external shareholders and a distinct self- governing structure ā€˜owned in commonā€™ by all who work in it. Scott Bader has expanded to be a global company with 7 Manufacturing sites and 9 Sales offices around the world. The founder Ernest Bader wanted to create an environment where profits would be shared amongst the workers, and believed that a business should be: ā€¢ Founded on ethical principles ā€¢ Organised democratically ā€¢ Contribute to the good of society This vision is highly consistent with the current expectations underpinning the movement on ESG reporting. Today Scott Bader features in the Employee Ownership Associationā€™s (EOA) 2020 Top 50 Report as one of the fifty largest employee-owned companies in the UK. It is a prime example of how a business can be run differently, whilst also being successful. As it cannot be taken over, the Company is able to think and act long term as a business, with colleagues fully involved in both the business strategy and operations. We continue to maintain the balance between our social purpose and our business needs as we pursue our ambitious 2036 Vision, in a way that lives up to our founder Ernest Baderā€™s vision.
  • 4. Scott Bader Supplier Partnership Manual 4 1 STRIVING FOR EXCELLENCE We are purpose-driven, fully meeting the expectations of our customers by continuously improving all our processes and products to deliver world-class business performance. OUR 7 STRATEGIC GOALS 3 ACTING BEYOND COMPLIANCE We are a trusted leader, proactively driving a safe, transparent and ethical chemical industry, promoting exemplary conduct to deliver products and processes that safeguard people and planet. 2 PIONEERING THE CIRCULAR ECONOMY We are a recognised circular economy practitioner, collaborating with our partners to optimise our combined resources for a waste and harm-free, closed-loop value chain. 4 DELIVERING VALUE TO SOCIETY We are advocating sustainability, sharing our know-how, profit and Commonwealth vision, and supplying products and services that provide real value to society. 5 UNLEASHING COLLEAGUESā€™ POTENTIAL We are driven by the diversity and creativity of our people who are empowered and motivated to make a difference through initiative and innovation at every level of the organisation. 7 PROTECTING OUR ENVIRONMENT We are a strong ambassador for the transition to a sustainable planet through our responsible use of our natural resources, our stewardship of clean energy and fresh water, and our commitment to zero emissions. 6 PARTNERING FOR SUCCESS We are at the heart of a global network of mutually-beneficial partnerships with suppliers, customers and world-leading allies who are engaged with our mission and share our vision. We envision a world where humanity thrives, without compromising the natural systems it depends on. Scott Bader provides essential technologies that address the challenges of our changing society and in doing so is a renowned, trustworthy partner that is globally admired for harnessing the power of chemistry as a force for good.
  • 5. Scott Bader Supplier Partnership Manual 5 The purpose of Scott Bader has been restated recognising that our ability to deliver for our customers depends on empowering our people. To this end the strategy and the steps required to implement the strategy have been summarised, with clear targets for 2025 within each of the three pillars of Humanity, Business, and Ecology as milestones on our journey towards the 2036 Vision. PEOPLE AND VALUES ā€¢ Integrity and honesty ā€¢ Commit and deliver ā€¢ Teamwork ā€¢ Diversity and Inclusion ā€¢ Fairness and equality ā€¢ Innovation and empowerment ā€¢ Compassion and care "Be the best we can be" APPROACH AND PRINCIPLES ā€¢ Safety and wellbeing ā€¢ Ethical business ā€¢ Sustainability ā€¢ Responsible stewardship ā€¢ Beyond compliance ā€¢ Promote Scott Bader values "To solve customer problems" IMPACT ON SOCIETY ā€¢ Reduced emissions ā€¢ Reduced waste ā€¢ Sustainable products ā€¢ Supplying sustainable industries ā€¢ Development of colleagues ā€¢ Charity and volunteering ā€¢ Investment in local communities "...and make a positive difference globally..." OUR 2036 VISION WAS DEVELOPED WITH REFERENCE TO THE UNITED NATIONS SUSTAINABLE DEVELOPMENT GOALS
  • 6. Scott Bader Supplier Partnership Manual 6 2. SCOPE This manual describes Scott Baderā€™s Quality and CSR requirements for suppliers and contractors, who provide raw materials, tolled products, additional processing, services and on-site contracting activities. This manual specifies the Quality and CSR requirements for Scott Bader Suppliers and does not supersede specifications or contractual agreements, which shall be reviewed and agreed, in addition to these requirements. Suppliers are required to cascade these requirements or equivalent to their own suppliers throughout the supply chain. Scott Bader may have additional specific requirements beyond the requirements of this manual, these will be issued by the Local Purchasing or QA teams. This may encompass Logistical requirements including booking in and site rules, additional regulatory paperwork and other legal requirements of the site you are supplying. If in doubt, please contact your Local Scott Bader Purchasing or QA contact. Scott Bader reserves the right to monitor suppliers, and where applicable, external manufacturer compliance, in line with this Partnership Manual. Suppliers and/ or external manufacturers that are not in compliance with this Partnership Manual are expected to implement corrective action and any future partnerships are at the discretion of Scott Bader. This manual specifies the Quality and CSR requirements for Scott Bader Suppliers. CSR
  • 7. Scott Bader Supplier Partnership Manual 7 We seek to develop long-term partnerships with our suppliers that are mutually beneficial. 3. PURPOSE These requirements in this manual are designed to support Scott Baderā€™s 2036 Vision, in particular, Acting beyond compliance and Partnering for Success. The purpose of this manual is to inform Scott Baderā€™s Suppliers of our core expectations regarding their Quality, Safety and Environmental Management, Ethics and Corporate Social Responsibilities. After reviewing this manual, a supplier should have a clear understanding of what is expected of them to ensure that all Scott Baderā€™s requirements and expectations are being met. We seek to develop long-term partnerships with our suppliers that are mutually beneficial. We work closely with suppliers, that reflect the values of Scott Bader, who develop greener solutions, promote sustainability at every opportunity and who share our commitment to achieve increasing levels of customer satisfaction, quality, safety, sustainability and ethics through continuous improvement and monitoring. We will conduct our business with the highest level of integrity. We will be honest and responsible in dealing with suppliers and contractors. Scott Bader expects our suppliers to deliver quality product on time with no defects at a cost that enables both of us to be competitive and viable. We expect our suppliers to be proactive and to alert us of any potential problems, changes in process or products and situations that may arise causing risk to our joint ability to meet our Quality, Regulatory and Ethical contractual obligations to our customers. We expect quality and timely delivery at a cost that is mutually competitive and viable.
  • 8. scottbader.com 8 4. QUALITY 4.1 QUALITY MANAGEMENT SYSTEMS Scott Bader expects all our key suppliers to be certified to, as a minimum, ISO 9001:2015 or actively working towards gaining certification, unless prior approval is obtained by Scott Bader The supplier shall maintain suitable procedures and work instructions and ensure that all persons including delivery drivers relating to the supplied products or services supplied are suitably trained and competent. Product must be delivered with appropriate paperwork, in the agreed packaging of good condition to allow for suitable storage and lot/batch numbers must be clearly visible and legible on each individual package. 4.2 CERTIFICATE OF ANALYSIS Where applicable all products must be delivered with a certificate of analysis, clearly detailing the test results of the delivered product, the batch/lot number and the manufacturing or expiry date of the delivered product in accordance with, where applicable, the agreed Scott Bader Purchasing Specification. Full traceability must be maintained by the supplier, with the delivered product being traceable back to base materials and equipment used to produce the product. 4.3 NON-CONFORMANCE In the event that a supplierā€™s product or service does not conform to the agreed specifications then Scott Bader will issue a Non-Conformance/Supplier Complaint. Once issued the supplier will acknowledge the complaint and commence investigation to the root cause with the expectation (unless agreed otherwise in writing) to fully investigate, complete and close out the Non-Conformance/Complaint including all corrective actions and preventative actions to ensure the issue does not re-occur. 4.4 CHANGE MANAGEMENT The supplier must inform Scott Bader of any changes to the product formulation, processing equipment (that is not like for like), manufacturing location, specification or packaging. In the case of a non ā€œforce majeureā€ change then notice of the change must be given at least 3 months before the change is implemented and must allow for continued supply of existing material for 6 months from notification. The supplier must have a change management process in place and this must be clearly communicated to Scott Bader. 4.5 RECORD KEEPING The supplier shall implement a suitable document control and record keeping process to ensure that records are available for, as a minimum, 36 months beyond the shelf life of the materials supplied to enable full traceability of the supplied product. Scott Bader expects all our key suppliers to be certified to, as a minimum, ISO 9001:2015
  • 9. Scott Bader Supplier Partnership Manual 9 5.0 ENVIRONMENT AND ENERGY Scott Bader expects all our suppliers to implement an Environmental and Energy Management System and certification to ISO14001:2015 and ISO 50001:2018 is preferred which will lower the risk rating of the supplier. Suppliers shall obtain, keep current, and comply with all required local Environmental permits. We aim to work and build partnerships with suppliers who actively seek to secure raw materials using non-crude oil or ā€˜Green/Bioā€™ feed materials and environmentally friendly processes, where possible. All suppliers should have an active waste reduction plan in place including for internal activities and for products and packaging supplied to Scott Bader. Suppliers should have a plan to monitor and actively reduce their Energy usage and GHG emissions in order to limit the impact on the environment. Supplierā€™s facilities shall be suitably controlled as to minimise emissions to air, land or water, this includes odour and noise disruptions in the local area. External manufacturers will comply with all applicable transportation laws. External manufacturers will have systems in place to ensure safe and secure transportation of materials, and such systems should be considered when: selecting logistics service providers (including warehouses and terminals), inspecting and labelling of transport containers, loading and unloading of transport containers, securing and sealing of transport containers and responding to emergencies. All suppliers should have an active waste reduction plan for internal activities, products and packaging.
  • 10. scottbader.com 10 6. OCCUPATIONAL HEALTH AND SAFETY MANAGEMENT Suppliers shall have sound H&S practices to prevent workplace accidents and injuries. Scott Bader expects all our suppliers to implement a Health & Safety Management System, including accident and near miss reporting. Certification to ISO 45001:2018 is preferred which will lower the risk rating of the supplier. Suppliers shall obtain, keep current, and comply with all required local health and safety permits and relevant regulations. Suppliers shall provide a safe and healthy environment to prevent workplace accidents and injuries and integrate sound health and safety management practices into their business. Workers shall have the right to refuse unsafe work and to report unhealthy working conditions. Suppliers shall identify, evaluate, and manage occupational health and safety hazards through a prioritised process of hazard elimination, substitution, engineering controls, administrative controls, and/or personal protective equipment. Occupational exposure to potential safety hazards and emergency situations shall be controlled through proper design, risk assessment, engineering controls, safe work procedures, emergency plans and response procedures, and mandatory trainings. Facilities and onsite accommodation for employees must safeguard individualsā€™ dignity, hygiene and safety. Their conditions must comply with national laws and relevant health and safety standards.
  • 11. Scott Bader Supplier Partnership Manual 11 7. CHEMICAL CONTROL LEGISLATION Scott Bader is a primarily a formulator of chemical mixtures and manufacturer of polymers that may be sold globally. We have obligations to communicate hazard and safe use information to our customers and to inform our suppliers of any additional suspected hazards or new uses of their products that are not covered by existing chemical safety assessments. Therefore, Scott Bader seeks to work closely with suppliers in ensuring both parties are able to comply with chemical control legislation around the world. Suppliers shall cooperate with Scott Bader in maintaining compliance of their products in the UK and of any Scott Bader products (mixtures or polymers) made using their supplied materials in any relevant market Scott Bader supplies. Communication on chemical inventory status of their materials globally is required and the supplier shall clarify the status of their Registrations (e.g., EU, UK, Turkey REACH), notifications (e.g. TSCA, DSL, AICIS, Japan ISHL/CSCL) as well as any industry declarable substances lists (e.g. GADSL). It is accepted that not all materials may be able to comply with all regions and the supplier shall clearly communicate their status in each jurisdiction and/or market (including food contact, personal care, automotive etc). The supplier shall work with Scott Bader to clarify, establish or maintain compliance as required and agreed with Scott Bader. Suppliers shall inform Scott Bader prior to sale if their product contains any controlled or restricted substances (REACH restrictions, RoHS, TSCA Section 6 rulings or Section 5 SNURS etc) that could reasonably be foreseen to affect the use of the substance by Scott Bader in their manufacturing site or in product mixtures sold in or outside of the UK (for example those subject to REACH Restrictions, Authorisation list substances, Candidate List substances, Prior Informed Consent, TSCA Section 12(b), Rotterdam convention, Stockholm Convention, Chemical Weapons Conventions, dual-use regulations etc.). All products supplied must comply GHS classification and labelling regulations (GB CLP) including provision of extended Safety Data Sheets (eSDS). Changes to product labels or SDS must be communicated to Scott Bader Regulatory Affairs as soon as practicable or within three months of the change occurring. This is to meet our legal obligations in other countries in a timely fashion and ensure we can communicate to our downstream users. The supplier should also communicate any expected changes in their products regulatory status or hazard classification as soon as possible to enable the supplier and Scott Bader to make any adjustments to processes, packaging or any downstream communication needs. All products supplied must comply with GHS classification and labelling regulations (GB CLP). GHS
  • 12. scottbader.com 12 8. ETHICS 8.1 NO CHILD LABOUR Child labour is not tolerated in any form. Suppliers shall not directly or indirectly employ children below the minimum age of 15, unless exceptions under ILO Minimum Age Convention No. 138 Article 6-7 apply. Suppliers should have a child labour policy and a plan for remediation if applicable. If a child is found working at a site associated with a Supplier, all remedial actions taken must be in the best interest of the child. It is of the highest importance to always protect children from being forced into harmful work. Employees younger than 18 years of age are acceptable, providing that they do not perform work that might jeopardise their health or safety, consistent with ILO Minimum Age Convention No. 138. Suppliers shall not require juvenile workers to work overtime or perform night-time work. 8.2 EMPLOYMENT IS FREELY CHOSEN There shall be no forced, bonded or involuntary prison labour or any form of human slavery, servitude or human trafficking. ā€˜Human traffickingā€™ means the recruitment, transportation, transfer, harbouring or receipt of persons, by means of the threat or use of force or other forms of coercion, of abduction, of fraud, of deception, of the abuse of power or of a position of vulnerability or of the giving or receiving of payments or benefits to achieve the consent of a person having control over another person, for the purpose of exploitation. Scott Bader strictly prohibits any exploitative labour practices or any associated criminal conduct within its supply chain. Workers shall not be required to lodge ā€œdepositsā€ or their passports / identity papers with their employer and are free to leave their employer after reasonable notice. Where applicable, suppliers must abide by the Modern Slavery Act 2015, or the local equivalent in their country, and be able to demonstrate compliance throughout their entire supply chain. 8.3 NON-DISCRIMINATION Suppliers shall not negatively discriminate based on race, colour, age, gender, sexual orientation, gender identity and expression, ethnicity or national origin, disability, pregnancy, religion, political affiliation, union membership, protected genetic information or marital status in hiring and employment practices unless such distinction is required by national law, such as BBBEE in South Africa. 8.4 HOURS OF WORK Employees should not be required to work more than the maximum regular and overtime hours allowed by the law of the country of operation. No more than 48 hours per week are worked on a regular basis and no more than 12 hours per week overtime on a regular basis. Overtime must be voluntary and not used to replace regular contracted hours. Workers must be compensated at a premium rate according to national law. Holidays should be granted in accordance with local laws and employees shall be given, except in extraordinary business circumstances, at least one day off per week. Child labour is not tolerated in any form, either directly or indirectly. We strictly prohibit exploitative labour or criminal conduct within our supply chain.
  • 13. Scott Bader Supplier Partnership Manual 13 8.5 WAGES AND BENEFITS Wages and benefits paid for the standard working week must meet, as a minimum, national legal standards. All workers shall be provided with written and understandable information about their employment conditions in respect to wages before they enter employment and about the particulars of their wages for the pay period concerned each time that they are paid including any deductions at a rate that is fair and reasonable by local standards and must be lawful and not discriminatory. Ensuring that the deductions from wages as a disciplinary measure shall not be permitted without the expressed permission of the worker concerned. All disciplinary measures should be recorded. 8.6 EMPLOYEE TREATMENT Every employee shall be treated with respect and dignity. Workers shall not be subject to any discrimination either directly or indirectly based on their gender, race, religion disability or any other protected characteristic or any form of physical, sexual or mental harassment or verbal abuse 8.7 AGENCY LABOUR If workers are sourced from a third party, suppliers must ensure that the third party is reputable and (if required) properly licensed. Suppliers must take reasonable steps to ensure that all workers supplied have the right to work in the country of operation and are engaged on terms that comply at least the minimum legal requirements in that country. 8.8 ANTI-BRIBERY AND CORRUPTION Scott Bader does not tolerate any form of bribery and corruption. We recognise that market practice varies across the territories in which Scott Bader does business and therefore, what is normal and accepted in one place may not be accepted in another. However, we are fully committed to complying with our obligations under all applicable legislation, including the UKā€™s Bribery Act 2010 and ensuring that no bribes or corrupt payments are made, offered, sought or obtained by anyone acting on behalf of Scott Bader, anywhere in the world and expects its supply partners to adhere to the same standards. 8.9 CONFLICT MINERALS Suppliers must ensure that products and goods supplied to Scott Bader do not contain metals or materials that are derived from minerals originating from conflict regions. Conflict minerals are tantalum, tin, tungsten and gold, also known as 3TG, and their derivatives that directly or indirectly finance or benefit armed groups. 8.10 LEAD FREE Scott Bader works to a ā€œlead freeā€ policy across the group to ensure the health of all our colleagues, while processing and working with raw materials. All suppliers must ensure that all products supplied to Scott Bader UK are free from lead. 8.11 SUB-CONTRACTORS Suppliers and contractors for Scott Bader must ensure any sub-contractors are aware of and comply with the requirements of this Supplier Partnership Manual. 8. ETHICS Every employee shall be treated with respect and dignity. Scott Bader does not tolerate any form of bribery and corruption.
  • 14. Scott Bader Supplier Partnership Manual 14 8.12 REPORTING MISCONDUCT An external manufacturer who believes that a Scott Bader employee or anyone acting on behalf of Scott Bader has engaged in illegal or otherwise improper conduct with respect to their business with the supplier should report the matter, in the first instance, to Scott Bader for resolution. Reports may be made through the Scott Bader Whistleblowing Hotline that is operated by an external service provider, Safecall, who can be reached at http:/ /www/safelink.co.uk/report. Any such report of potential misconduct shall not adversely affect the parties relationship. 8.13 SANCTIONED PARTIES Any supplier and/or shipper shall not use an external manufacturer for services or equipment which: (a) is located in any country subject to United Nations, United States or European Union sanctions (or acting on behalf of persons or entities located in such countries); or (b) appears on lists of restricted or prohibited persons maintained by the United Nations, United States or the European Union or the country of manufacture, origin, destination of the cargo. Where applicable, a shipper shall screen all vessels, containers and other equipment and their owners to ensure compliance with this requirement. 8. ETHICS
  • 15. scottbader.com 15 9. SUPPLIER APPROVAL AND MONITORING Scott Bader is committed to working with suppliers whose values are aligned to ours. 9.1 APPROVALS Scott Bader applies a risk-based process to supplier approval, based on several different criteria including Business Impact to Scott Bader, ISO approvals, single sourcing and CSR activities including Ecovadis score. All suppliers will be required to complete a Supplier approval questionnaire and agree to the requirements of this Manual prior to approval. Once the questionnaire has been reviewed a risk score will be allocated and approval can take place. Based on the risk score this approval may involve a full supplier audit, either on site or desk based. Suppliers must agree to allow a Scott Bader representative on site to carry out a full system/process audit if required. 9.2 ECOVADIS Scott Bader is committed to working with suppliers whose values are aligned to ours. Scott Bader has signed up to EcoVadis, a world leading provider of business supplier sustainability ratings and improvement tools for global supply chains. We will leverage this platform to reduce risk, encourage innovation and deliver on our commitment to put sustainability and ethics at the core of what we do. EcoVadis support Scott Baderā€™s mission to measure, monitor and improve supplier performance across key sustainability criteria and identify high-performing partners willing to collaborate with us. It is recommended that all suppliers to Scott Bader are registered on Ecovadis and that their scorecard is shared with us. Completion of this will reduce the risk score of the supplier approval. Scorecards will be reviewed; minimum category scores may be set and continual improvement of the Ecovadis score may be required to maintain approval as a supplier. 9.3 MONITORING Key Suppliers will be monitored based OTIF and Quality performance, including complaints and supplier responsiveness. Suppliers monitored will be listed in the following categories ā€¢ Good ā€¢ Satisfactory ā€¢ Needs Improvement For Suppliers identified in the ā€œNeeds Improvementā€ category Scott Bader may request an improvement plan and / or surveillance audit and failure to improve their performance may result in approval being revoked. Suppliers will also be monitored against the CSR requirements of this manual and any breaches which do not fit in with the ethics and values of Scott Bader may also result in approval being revoked. All suppliers complete a questionnaire and agree to the requirements of this manual prior to approval.
  • 16. Scott Bader Supplier Partnership Manual 16 10. REVISIONS Any updates to the Supplier Partnership Manual will be posted on the Scott Bader website. Suppliers shall regularly check the current version they have on hand with the latest version. All changes to this manual shall be identified on the revision table below. Scott Bader welcomes any feedback about corrections and suggestions for improvement including suggestions for adding additional information. REV DATE UPDATES APPROVED BY 0.1 20/11/2021 Final group draft D.Black 0.2 Addition of misconduct and sanctions clauses in section 8 D.Black 10.1 REVISION TABLE scott bade r.com 12 8.0 ETHICS 8.1 CHI LD LAB OUR Chil d labo ur is not tole rate d in any form . Sup plie rs shal l not dire ctly or indi rect ly emp loy chil dren belo w the min imu m age of 15, unle ss exce ptio ns und er ILO Min imu m Age Con ven tion No. 138 Arti cle 6-7 app ly. Sup plie rs sho uld hav e a chil d labo ur poli cy and a plan for rem edia tion if app licab le. If a chil d is foun d wor king at a site asso ciat ed with a Sup plie r, all rem edia l acti ons take n mus t be in the best inte rest of the chil d. It is of the high est imp orta nce to alwa ys prot ect chil dren from bein g forc ed into harm ful wor k. Emp loye es you nge r than 18 year s of age are acce ptab le, prov idin g that they do not perf orm wor k that mig ht jeop ardi se thei r hea lth or safe ty, con siste nt with ILO Min imu m Age Con ven tion No. 138 . Sup plie rs shal l not requ ire juve nile wor kers to wor k ove rtim e or perf orm nigh t-tim e wor k. 8.2 EMP LOY MEN T IS FRE ELY CHO SEN The re shal l be no forc ed, bon ded or invo lunt ary pris on labo ur or any form of hum an slav ery, serv itud e or hum an traf fick ing. ā€˜Hum an traf fick ingā€™ mea ns the recr uitm ent, tran spo rtat ion, tran sfer , harb ouri ng or rece ipt of pers ons , by mea ns of the thre at or use of forc e or othe r form s of coe rcio n, of abd ucti on, of frau d, of dec epti on, of the abu se of pow er or of a pos ition of vuln erab ility or of the givi ng or rece ivin g of pay men ts or ben efits to achi eve the con sent of a pers on hav ing con trol ove r ano ther pers on, for the purp ose of exp loita tion . Sco tt Bad er stric tly proh ibits any exp loita tive labo ur prac tice s or any asso ciat ed crim inal con duc t with in its sup ply chai n. Wor kers shal lnot berequ ired tolodg eā€œdep osit sā€orthei rpass port s/iden tity pap ers with thei remp loye rand are free toleav ethei remp loye rafte rreas ona ble noti ce.Wh ere app licab le,supp liers mus tabid ebythe Mod ern Slav ery Act 201 5,orthe loca lequ ivale ntin thei rcoun try, and beable todem onst rate com plian cethro ugh out thei renti resupp lychai n. 8.3 NO N-D ISCR IMI NAT ION Sup plie rs shal l not neg ativ ely disc rimi nate base d on race , colo ur, age , gen der, sexu al orie ntat ion, gen der iden tity and exp ress ion, ethn icity or nati ona l orig in, disa bilit y, preg nan cy, relig ion, poli tica l affil iatio n, unio n mem bers hip, prot ecte d gen etic info rma tion or mar ital stat us in hirin g and emp loym ent prac tice s unle ss such dist inct ion is requ ired by nati ona l law, such as BBB EE in Sou th Afri ca. 8.4 HO URS OF WO RK Emp loye es sho uld not be requ ired to wor k mor e than the max imu m regu lar and ove rtim e hou rs allo wed by the law of the cou ntry of ope ratio n. No mor e than 48 hou rs per wee k are wor ked on a regu lar basi s and no mor e than 12 hou rs per wee k ove rtim e on a regu lar basi s. Ove rtim e mus t be volu ntar y and not used to repl ace regu lar con trac ted hou rs. Wo rker s mus t be com pen sate d at a prem ium rate acco rdin g to nati ona l law. Hol iday s sho uld be gran ted in acco rdan ce with loca l laws and emp loye es shal l be give n, exce pt in extr aord inar y bus ines s circ ums tanc es, at leas t one day off per wee k. Child lab our is not tolera ted in any form, eith er dire ctly or ind irec tly. We strictl y pro hib it exp loit ativ e lab our or crim ina l con duc t wit hin our sup ply cha in. Employee, Environment, Social and Governance report 2020 scottbader.com 1 SCOTTBADER.COM SCOTT BADER SUPPLIER PARTNERSHIP MANUAL Scott Bader Supplier Partnership Manual 6 2.0 SCOPE This manual describes Scott Bader Co Ltd.ā€™s Quality and CSR requirements for suppliers and contractors, who provide raw materials, tolled products, additional processing, services and on-site contracting activities. This manual specifies the Quality and CSR requirements for Scott Bader Suppliers and does not supersede specifications or contractual agreements, which shall be reviewed and agreed, in addition to these requirements. Suppliers are required to cascade these requirements or equivalent to their own suppliers throughout the supply chain. Scott Bader may have additional specific requirements beyond the requirements of this manual, these will be issued by the Local Purchasing or QA teams. This may encompass Logistical requirements including booking in and site rules, additional regulatory paperwork and other legal requirements of the site you are supplying. If in doubt, please contact your Local Scott Bader Purchasing or QA contact. This manual specifies the Quality and CSR requirements for Scott Bader Suppliers. CSR
  • 17. scottbader.com 17 SCOTT BADER GROUP COMPANIES Registered office address: Scott Bader Company Limited, Wollaston Hall, Wollaston, Wellingborough, Northamptonshire, NN29 7RL. Registered in England No. 00189141. SCOTTBADER.COM Head Office Scott Bader Company Limited Wollaston, England Tel: +44 (0) 1933 663100 Email: enquiries@scottbader.com Scott Bader France Amiens, France Tel: +33 3 22 66 27 66 Email: info@scottbader.fr Scott Bader Spain Barcelona, Spain Tel: +34 93 553 1162 Email: diazs@scottbader.es Scott Bader Germany Weiden, Germany Tel: +49 961 401 84474 Email: composites@scottbader.de Scott Bader Ireland Dublin, Ireland Tel: +353 1801 5656 Email: composites@scottbader.ie Scott Bader Scandinavia Falkenberg, Sweden Tel: +46 346 10100 Email: composites@scottbader.se Scott Bader Eastern Europe s.r.o. Praha 6, Czech Republic Tel: +420 (0) 485 111 253 Email: composites@scottbader.cz Scott Bader Croatia Zagreb, Croatia Tel: +385 1 240 6440 Email: info@scottbader.hr Scott Bader North America Stow, OH, USA Tel: +1 330 920 4410 Email: info@scottbader-na.com Scott Bader North America Mocksville, NC, USA Email: info@scottbader-na.com Scott Bader ATC Drummondville, Canada Tel: +1 (819) 477 1752 Email: enquiries@scottbader.com Scott Bader South Africa Hammarsdale, South Africa Tel: +27 31 736 8500 Email: composites@scottbader.co.za Scott Bader Middle East Dubai, United Arab Emirates Tel: +971 481 50 222 Email: info@scottbader.ae Scott Bader Asia Pacific Shanghai, China Tel: +86 (21) 5298 7778 Email: info@scottbader.cn Scott Bader Japan KK Yokohama, Japan Tel: +81 (0) 45 620 3745 Email: enquiries@scottbader.com Scott Bader Australia Perth, Australia Tel: +61 (08) 9418 4555 Email: info@scottbader.com.au Saryen Scott Bader Pvt. Ltd Mumbai, India Tel: +91 22 4220 1555 Email: info@satyenpolymers.com NovaScott Especialidades QuĆ­micas Ltda Civit II, Serra, ES 29165-973, Brazil Tel: +55 27 3298 1100 Email: info@novascott.com.br Scott Bader Italy Emilia Romagna, Italy Tel: +39 3454534391 Email: enquiries@scottbader.com